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Over the years the Shipbuilding Division of Bethlehem Steel has constructed 

 over 3.000 ships of nearly every type and description. We currently operate 8 

 shipyards although most of our new construction is concentrated at our shipyard 

 at Sparrows Point, Maryland. It is in this yard which has been engaged con- 

 tinuously in shipbuilding since the turn of the century that we are now construct- 

 ing 265,000 DWT tankers, the largest tankers that have ever been constructed in 

 this country. 



Since Bethlehem's principal expertise relates to the design and construction of 

 ships, including very large crude carriers (VLCC's), the majority of our com- 

 ments will be addressed to the Maritime Administration's action, the Coast 

 Guard's proposal, and to the draft IMCO convention's provisions pertaining to 

 segregated ballast standards. 



Bethlehem shares the view expressed by the Congress in enacting the Ports 

 and Waterways Safety Act of 1972 that additional efforts must be made to reduce 

 pollution of the world's oceans. At the same time we recognize that the 

 strengthening of existing standards and regulations relating to the construction 

 and operation of ships can contribute significantly to the abatement of marine 

 pollution. 



The task of developing meaningful, effective standards which will contribute 

 to the abatement of marine pollution is not an easy one. Before any intelligent 

 determinations can be made, a number of complex questions must be addressed. 

 Are the standards established by international convention adequate to deal with 

 the problem or is there a need for supplemental domestic legislation or regulation? 

 If supplemental laws or regulations are considered necessary for protection of 

 U.S. waters how can such laws or regulations be effectively enforced in view of 

 the fact that more than 95 percent of U.S. oil imports arrive at United States 

 shores in foreign-flag vessels? Should the primary thrust of standard setting be 

 directed to traffic control and other systems which seek to minimize the number 

 of accidents or should the focus be on design features which might minimize oil 

 outflow in the event that an accident does occur? 



As a result of our experience, we have reached a number of conclusions which 

 are relevant to any discussion of standards aimed at abating marine pollution. 

 They are as follows : 



(1) In view of the large number of approaches, systems, equipment, and 

 design alternatives available, it is essential that any conclusions reached as 

 to the relative merits of possible alternatives be based on careful considera- 

 tion of adequate amounts of data and that resources be directed to those 

 solutions which are likely to prove most cost-effective. 



(2) It generally makes more sense to focus on methods of preventing ma- 

 rine accidents in the first place rather than to focus on methods by which 

 pollution can be minimized in the event that an accident does occur. 



(3) Whatever the nature of standards considered to be necessary, it is 

 infinitely preferable to have such standards established by international 

 agreement rather than by unilateral action. 



(4) To the extent that supplemental standards in the area of vessel de- 

 sign are considered necessary for the i>rotection of U.S. waters, they must 

 be imposed in such a way that they will be generally applicable to and en- 

 forceable against foreign as well as U.S. flag vessels. 



THE NEED TO DEVELOP ADDITIONAL DATA 



The Maritime Administration's recent environmental impact statement re- 

 quired 100 pages to discuss various alternatives relevant to marine pollution. 

 Although that statement attempts to address design alternatives in terms of 

 their relative cost-effectiveness, the statement recognizes in a number of different 

 places that meaningful cost-effectiveness comparisons are hindered by serious 

 v/eaknesses in the data base. 



The significance of this fundamental inadequacy represents a major obstacle 

 to be overcome if national standards are to be established. Its importance is 

 illustrated by the Coast Guard's proposed rule which would require that all new 

 tankers be constructed with double bottoms. 



In developing its proposed rule, the Coast Guard placed very heavy reliance 

 on the projected effectiveness of that particular design feature as described in 

 a report entitled "Report on Study i_Segregated Ballast Tankers" (Study I) 

 a note submittal by the United States to IMCO in 1972. Because of the signifi- 

 cance which has been attached to Study I, we asked Booz- Allen Applied Research 



